Brief Fact Summary. Respondent committed murder when he was age 17. He was tried and sentenced to death after he turned 18.
Synopsis of Rule of Law. “The Eighth and Fourteenth Amendments forbid imposition of the death penalty on offenders who were under the age of 18 when their crimes were committed.”
Issue. “[W]hether it is permissible under the Eighth and Fourteenth Amendments to the Constitution of the United States to execute a juvenile offender who was older than 15 but younger than 18 when he committed a capital crime.”
Held. No. The Supreme Court of the United States first established the applicability of the Eight Amendment, as well a precedent of the application of the death penalty to minors. Traditionally, minors did not face capital punishment. It noted that a “consensus” of the country is against the application of the death penalty to juveniles.
The Supreme Court noted the gravity of capital punishment and its application. “Capital punishment must be limited to those offenders who commit ‘a narrow category of the most serious crimes’ and whose extreme culpability makes them ‘the most deserving of execution.’” The Supreme Court further noted that juveniles are different, in that: they lack maturity and understanding of responsibility; are “more vulnerable or susceptible to negative influences and outside pressures, including peer pressure”; and that “that the character of a juvenile is not as well formed as that of an adult.” Having recognized the fact that a juvenile is not “the worst” offender, “the penological justifications for the death penalty apply to them with lesser force than to adults.”
Construing and applying the Eighth Amendment in the light of our evolving standards of decency, we therefore conclude that such punishment is excessive and that the Constitution places a substantive restriction on the State's power to take the life of a mentally retarded offender.View Full Point of Law
Concurrence. The concurring justices applauded the Supreme Court’s application of “[t]he evolving standards of decency that have driven our construction of this critically important part of the Bill of Rights foreclose any such reading of the Amendment.”
Discussion. “The differences between juvenile and adult offenders are too marked and well understood to risk allowing a youthful person to receive the death penalty despite insufficient culpability.